### July 31, 2015

Exemption No. 12263 Regulatory Docket No. FAA

–2015

–2099

Mr. Michael Wallace President Kentucky Windage UAV, LLC 21 Sinking Fork Road Cadiz, KY 42211

Dear Mr. Wallace: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated May 25, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofKentucky Windage UAV, LLC (hereinafter petitioner or operator) for an exemption

. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial photography for photogrammetric and preliminary agriculture scouting purposes

. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification

The UAS proposed by the petitioner is an AgEagle Robotic Aircraft System

.

### 2 The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, SubpartH

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Sub part H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary.
The Basis for Our Decision You have requested to use a UAS for aerial data collection1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos

. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Kentucky Windage UAV, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a)

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3 and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Kentucky Windage UAV, LLC is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the AgEagle Robotic Aircraft System when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of

### 4 exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

### 5 government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

-determined location within the private or controlled

-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The

### 6 exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

. 22. All aircraft operated in accordance with this exemption must be identified by serial
number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be

### 7 reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used;
e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8 This exemption terminates on August 31, 2017, unless sooner superseded or rescinded. Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

EnclosuresU.S. Department ofTransportation I Federal Aviation Administration Docket Management System 1200 New JerseyAve., SE Washington, DC 20590

For: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Concerning Operation ofan Unmanned Aerial System Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012.

Submitted: May 25, 2015

Michael Wallace President Kentucky Windage UAV, LLC 21 Sinking Fork Road Cadiz KY, 42211 270-889-3173 mikewallace@kentucky winageuav.com



### Kentucky WindageUA V LLC 270-889-3173Contents



### 1. Overview of Exemption 2. Applicable Legal Standard under Section 333 3. Summary Background ofthe AgEagle Robotic Aircraft System 4. Scope of Mission Operations 5. Evidence ofAirworthiness 6. Safety Features 7. Mandatory Operating Conditions 8. Operator Requirements 9. Appendices, Attachments, and Confidentiality of Proprietary Documents 10. Summary & Conclusion

Appendix A 

### Overview of Regulations from which Exemption is Requested; Including Explanation in the Context ofAppropriateness, Safety, and Benefit to the Public Interest. Appendix B 

### Company Profile Appendix C 

### Technical Specifications ofthe AgEagle Robotic Aircraft System
1. Physical Characteristics ofthe AgEagle 2. Performance Characteristics ofthe AgEagle 3. Maintenance 4. Reliability 5. FaultTolerance 6. Emergency Procedures and System Failures 7. Command and Control Systems



### KentuckyWindageUA V LLC 270-889-3173May 25th, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Kentucky Windage UAV, LLC (Kentucky Windage UAV), seeks an exemption from Federal Aviation Regulations ("FARs") listed in Part 1. "Overview of Exemption" listed below and further detailed in Appendix A.

The requested exemption would permit market research and commercial operations for the 2015 release ofthe AgEagle Robotic Aircraft System ("AgEagle") manufactured by AgEagle, LLC; Neodesha, Kansas, USA; forwhich Kentucky Windage UAV is a technology advisor, authorized training partner, and reseller.


### 1. Overview of Exemption The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21; Subpart H 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.119(c); 14 C.F.R. 91.151 (a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2);



### KentuckyWindage UA V LLC 270-889-317314 C.F.R. 91.417(a)

While a collective case for exemption is made within this letter, Appendix A takes care to discuss each rule listed prior in relevant context to the request; showing why exemption from the FARs of concern are appropriate, provide an equivalent level of safety, and are in the public interest.


### 2. Applicable Legal Standard under Section 333 Kentucky Windage UAV submits that grant ofthis exemption application for use ofthe AgEagle in precision agriculture, market research, surveying, mapping and inspection operations will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction ofsmall Unmanned Aerial Systems ("sUAS") into the National Airspace system ("NAS") if it can be accomplished safely. This law directs the Secretary ofTransportation to consider whether certain sUASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of sUAS do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light ofthe following:

• The size, weight, speed, and operational capability ofthe sUAS.

• Operation ofthe sUAS in close proximity to airports and populated areas.
• Operation ofthe sUAS within visual line ofsight ofthe operator.

Reform Act 333(b)(1) states that ifthe Secretary determines that such vehicles "may operate safely in the national airspace system", the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ld. 333(c)1

.
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement ofa regulation prescribed under

1 http://www.gpo.gov/fdsys/pkg/CRPT-112hrpt381/pdf/CRPT-112hrpt381.pdf



### KentuckyWindage UA V LLC 270-889-3173subsection (a) or (b) ofthis section or any ofsections 44702-44716 ofthis title ifthe Administrator finds the exemption is in the public interest.

49 U.S.C. 44701 

### (f). See also 49 USC 44711 (a); 49 USC 44704; 14 CFR 91.203(a)(1).

The grant ofthe requested exemption is in the public interest based on the clear direction in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.



### 3. Summary Background ofthe AgEagle Robotic Aircraft System The AgEagle is a battery-powered electric fixed wing aircraft with a wingspan of approximately 56 inches and a take offweight of approximately 7.5 pounds including payload. The AgEagle is programmed and operated primarily using cellular data network services, with the Pilot In Command ("PIC") overseeing operations using a laptop, tablet computer or smartphone connected to the Internet (usually over the same cellular data network). The AgEagle can also be piloted over a 900 MHz radio using a laptop, tablet, or smartphone. Failsafe controls for emergency landings are also available via a 900 MHz industry-standard transmitter 

### I receiver.


### 4. Scope of Mission Operations The primary role ofthe AgEagle is aerial-based land survey in sparsely-populated rural
areas including the acquisition ofaerial photography for photogrammetric and preliminary "scouting" purposes; primarily in the precision agriculture market space. The AgEagle is equipped to carry either still-shot or video cameras, as well as still-shot
cameras that have been modified to detect near-infrared spectra in wavelengths attuned to plant health. Ultimately, the AgEagle system enables land stakeholders to make informed decisions in the context ofacreage. In the case of industries such as agriculture, the goal is enhanced land management and resource conservation that
saves the land operator input costs while maximizing yield.

As described in detail following, the scope ofthis exemption would permit the AgEagle to operate commercially in controlled conditions on private ground with the permission of the landowner and/or operator at low altitudes in a limited flight duration over an



### KentuckyWindageUAV LLC 270-889-3173airspace that is inherently limited in range. Furthermore, the relatively small size, low weight, and lack of hazardous payload (fuel) when compared to conventional manned aircraft make the AgEagle a lower-risk alternative to conventional manned aircraft designed to perform similar missions.



### 5. Evidence ofAirworthiness Critical to our exemption application is evidence ofthe airworthiness ofthe AgEagle robotic aircraft solution. Since inception of its proprietary airframe design, AgEagle, LLC believes that it has shown compliance through a history offlight operations totaling approximately 19,080 operational hours2. Furthermore, the AgEagle solution is a product that is delivered to the customer fully rigged and fight tested. The AgEagle is sold as a complete product solution. Should the AgEagle not be airworthy, then a lack of sales would justify this conclusion and consumers would not continue to purchase the AgEagle.

The confidence offoreign regulatory bodies with respect to regular commercial use of the AgEagle has been already been proven; specifically in Australia. Falcon UAV, the AgEagle retailer for Australia (http://www.falconuav.com.au), has applied for and received a UAV Operator's Certificate from the Australian Civil Aviation Safety Authority ("CASA"). Falcon UAV is currently operating the AgEagle commercially underthis certificate.


### 6. Safety Features The criteria set forth in current regulation specify the substantive showings ofthe safety and fitness ofa device for operation to ensure that the FAA has sufficient basis to evaluate the aircraft's safety. The AgEagle has a significant set of automated features provided by DroneDeploy, a San Francisco, California-based UAV solutions company that provides a hardware 

### I software solution that ensures safe takeoff, flight and landing in all but extreme conditions. Further details of operation can be found in Appendix C.

2 As of Dec 2014, AgEagle staff and customers have performed over 6,360 flights, logging 19,080 hours offlight time with the first generation AgEagle regarding both development and release versions. The current generation product, has achieved
over 480 flights and 1,440 hours offlight time globally by AgEagle and its customers. This is a significant amount offlight time collected to understand and refine the AgEagle sUAS as a product. AgEagle, LLC has been approved a Section 333 waiver
as of 5-1-2015, Excepmtion No. 11480, Regulatory Docket No FAA-2014-1104.



### KentuckyWindage UA V LLC 270-889-3173Facilitated by the DroneDeploy solution, automated safety functions and safety-enhancing features ofthe AgEagle include:

• Automated preflight system performance checks and calibrations

• A preflight checklist for the sUAS operator
• A one-button "hit the deck" collision avoidance command which causes the aircraft to drop from its cruising altitude and loiter at 50 feet AGL.
• Automated condition and fault detection, warnings, and predefined responses to
a number offlight and system conditions including:

o High winds with system and user defined safety thresholds

o Low battery with system and user defined safety thresholds

o High temperature and other hardware safety threshold monitors

o An automated return protocol for a lost communication link
• Predefined responses to flight parameters exceeding the aforementioned safety thresholds include behavior such as:

o Attempting to reestablish radio communication

o Returning to the home position to loiter

o Returning to the home position to land

o Landing at the current position

• In the case ofa lost GPS fix, a non-automated flight mode is enabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle.



### 7. Mandatory Operating Conditions The requested exemption would permit the commercial operation ofthe AgEagle under the following restrictions:

• Operations will be performed in Class G Airspace.

• Operations will be conducted 5 nautical miles outside of medium to large airports 

### 3

• Operations will be conducted outside of U.S. Military Bases, U.S. National Parks4
and posted Temporary Flight Restrictions ("TFRs")5

. • Operations will be performed at an altitude of no more than 400 foot above ground level ("AGL") at a target speed of40 knots.

• Operations will be performed on private property with documented permission of the landowner and 

### I or land operator.

3 As illustrated on the World VFR map on http://skyvector.com 4 As illustrated on https://www.mapbox.com/drone/no-fly/# 5 As Illustrated on the FAA TFR Map http://tfr.faa.gov/tfr map ims/htmllindex.html



### KentuckyWindage UA V LLC 270-889-3173• The aircraft will be operated in the field with both a Pilot In Command ("PIC") and
a Visual Observer ("VO").

• The aircraft will remain within the visual line-of-sight ofthe PIC for the duration of the mission.

• For the duration ofthe mission, the VO will maintain direct voice contact with the PIC.

• Operations will occur during daytime hours under visual meteorological conditions.

• The aircraft will be operated in sparsely populated areas away from large assemblies of people and heavily trafficked roads.

• Any additional State and 

### I or Local permits will be obtained prior to operation.



### 8. Operator Requirements Given the comprehensive set of safety features built-in to the AgEagle, Kentucky Windage UAV proposes the following operator requirements in good faith with the safety ofthe National Airspace being paramount:

• The operator must have successfully completed and passed the FAA private pilot written examination or an FAA recognized equivalent.

• The operator must have completed a training program authorized by AgEagle, LLC for operation and maintenance ofthe AgEagle robotic aircraft system.
Kentucky Windage UAV notes that the FAA has found that the aforementioned safety factors have been sufficient to allow operation ofsUASs by operators in the context of operations pursuant to public COAs6. The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated with the grant of airmen's certificates per 49USC 44701 (f).

• In addition, the operator will submit to a security background check equivalent to that currently required to obtain a private pilot's license. The FAA has made it clear in preceding exemptions7 approved for operations in the same context that this type of security screening is critical to safety ofthe National Airspace; but as no official security screening procedures currently exist in the context of

6 See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, July 30, 2013. 7 See exemption approvals 11567, 11110, and 11136



### Kentucky Windage 

### UAV LLC 270-889-3173sUAS operation, Kentucky Windage UAV is willing to work with a representative from the FAA and 

### I orthe Department of Homeland Security directly to ensure this qualification is met.



### 9. Appendices, Attachments, and Confidentiality of Proprietary Documents Pursuant to this exemption from the FARs setforth above, Appendix A outlines the specifics ofthis request in detail so as to illustrate the applicant's understanding oftheir impact with regards to the safety ofthe National Airspace. As a steward of such, Kentucky Windage UAV has provided contextual detail pertaining to the operation of Kentucky Windage UAV as a company in Appendix B; as well as the technical specifications of our preferred sUAS platform, the AgEagle in Appendix C.

Additional documents pertaining to the specific maintenance and operation ofthe AgEagle are proprietary to Kentucky Windage UAV and AgEagle LLC. As such, Kentucky Windage UAV requests that such documents be held as confidential by the FAA as such time as said documents are provided to the FAA for review. Kentucky Windage UAV can and will provide these documents on request, but asks for a direct communication with an FAA liaison to provide the materials as such.


### 10. Summary & Conclusion To summarize, we the applicant seek an exemption; outlined in specific detail in Appendix A for the allowance of market research and commercial operations of a small unmanned vehicle in surveying, mapping and inspection operations. Approval ofthe exemption allowing market research and commercial operations ofthe AgEagle for surveying, mapping and inspection operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve significantly larger aerial vehicles compared to the AgEagle, carry a significant quantity of combustible fuels, and require an on-board multi-person crew in piloting, observation, and survey roles. These operations require air transit to and from the location ofthe activity, and said operations have the propensity to include congested environments in close proximity to physical obstacles and 

### I or presence ofthe general public. By contrast, the AgEagle weighs 7.5 lbs including payloads, uses a battery for power, does not require use ofthe National Airspace in transit to and from the area of activity,
removes the need for airborne pilot and crew, and poses less risk to people and infrastructure on the ground.



### KentuckyWindageUA V LLC 270-889-3173In the context of air safety and national security, the AgEagle possesses the following attributes:
• A small to modest overall size; consisting of a 56 inch wingspan and a weight of 7.51bs.

• A limited range governed by an approximate 40 minute operational time with fly-away failsafes.
• Load carrying capacity limited to a single sensor approximate to the size of a
consumer point-and-shoot camera.
• A cruising speed of approximately 35 knots governed by software failsafes.

• Multiple failsafe measures inherent to the design ofthe system implemented to
ensure safe flight, recovery and incident mitigation.
• No payload of explosives, combustibles, or other dangerous materials, such as fuel. Given the aforementioned attributes in comparison to existing aircraft currently in operation in the national airspace, the AgEagle poses little if any threat to national security by the grant ofthe requested exemptions.

The operation ofthe AgEagle for market research, surveying, mapping and inspection operations in accordance with the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting AgEagle from the airworthiness requirements in Part 

### 21 of 

### 14 CFR.

The satisfaction ofthe criteria set forth in Section 333 ofthe Reform Act (i.e. size, weight, speed, operating capabilities, operation within Visual Line-Of-Sight ("VLOS") and lack of proximity to airports, populated or areas national security) and demonstrated equivalent level ofsafety as it relates to the requirement for FAA pilot certification, provide adequate if not significantjustification for the grant ofthe requested exemptions allowing Kentucky Windage UAV commercial operation ofthe AgEagle in agricultural market research, surveying, mapping and inspection operations.

In conclusion, the safe operation ofthe AgEagle Robotic Aircraft System is of utmost concern, and safety remains paramount. Kentucky Windage UAV intends to operate within the spirit ofall applicable FAA regulations and will adhere to any further refinements. The operation ofsUAS for precision agriculture in remote rural areas can and will be beneficial to the farmers, ranchers and landowners ofthis nation; as Kentucky Windage UAV operators and observers intend to perpetuate the "safety first" mindset upheld by the FAA, while mitigating all risk to personnel and property both in the air and on the ground.



### KentuckyWindage UA V LLC 270-889-3173Kentucky Windage UAV understands that the FAA is working diligently to safely integrate small Unmanned Aerial Systems into the National Airspace; and as such, requirements for safe operations could be subject to change. That said, Kentucky Windage UAV is prepared to amend or append this request in order to satisfy the requirements ofsafe operation as the requirements continue to evolve. Please do not hesitate to contact us concerning any additional requirements or clarification.

With sincere regards,

Michael Wallace President Kentucky Windage UAV, LLC



### Kentucky WindageUA V LLC 270-889-3173Appendix A Overview of Regulations from which Exemption is Requested; Including Explanation in the Context ofAppropriateness, Safety, and Benefit to the Public Interest.

The regulations from which the exemption is requested are as follows:
14 C.F.R. Part 21, Subpart H & 91.203(a)(1):Airworthiness Certificates As the FAA continues the work ofdeveloping airworthiness standards for unmanned aerial systems, Kentucky Windage UAV seeks an exemption from the requirements for
a certificate ofairworthiness as set forth in 14 C.F.R. 91.203(a)(1); and in turn 14 C.F.R. Part 21. Kentucky Windage UAV asks for consideration ofthese exemptions in the context ofthe size, weight, speed, operational capability and the use of said system outside ofthe operational range of airports and away from populated areas. The AgEagle Robotic Aircraft System weighs approximately 7.5 lbs fully loaded with a wingspan of 56 inches. The AgEagle carries no pilot or passenger, carries no explosive materials orflammable liquid fuels, and operates at a relatively low altitude and slow speed exclusively within confines of private property. Given the small size and weight ofthe aircraft and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Furthermore, these criteria demonstrate thatthe AgEagle operating underthe conditions proposed herein, will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) which has been issued an airworthiness certificate.
14 C.F.R. 45.23(b), 91.9(c) 

### &91.203(b): Marking ofthe Aircraft Regulation 45.23(b) provides that the registration number ofthe aircraft must be on display prefixed by the Roman capital letter 

### "N". The regulation also states that lettering identifying the aircraft as in the "limited," "restricted," "light-sport," "experimental," or "provisional" category must be displayed near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high. In conjunction, regulation 91.9(c) provides that no person may operate a U.S.registered civil aircraft unless that aircraft is identified in accordance with part 45.

Given that the AgEagle has no cabin, cockpit, or pilot station, attempting to mark such
areas would be futile. Furthermore, it is unclear at the time ofwriting this request as to whether or not the AgEagle would actually fit into one ofthe aforementioned categories
as official marking systems for sUAS have not yet been established for operations



### Kentucky Windage UA V LLC 

### 270-889-3173inside the NAS. That said, Kentucky Windage UAV is prepared to register and display said registration number for any AgEagle flying under exemption if the decision regarding this exemption requires it. Should display ofa registration number be required
on the aircraft, Kentucky Windage UAVwill make every effort to display the lettering in a high visibility format on the aircraft in lieu ofspecific guidelines governing registration numbers in the context of sUAS. As pursuant to regulation 91.9(c), Kentucky Windage UAV believes that our cooperation with marking regulations that can reasonably be complied with in the context ofthe exemption should fulfill this requirement. As pursuant to regulation 91.203(b), the relative size size and therefore lack of any cabin or cockpit to hold personnel or passengers is non-existent. As such, it would be impossible to display any airworthiness certificate for concerned passengers and crew even ifthe certificate was indeed required. Kentucky Windage UAV recognizes that the FAA has determined in prior exemptions that relieffrom 91.203(b) is not necessary; allowing relevant materials to be kept accessible to the operator in compliance with the regulations. However, Kentucky Windage UAV respectfully requests that that the record pertinent to this exemption state as much in the order ofdue process so as to ensure a meaningful level of compliance. As such, Kentucky Windage UAVwill require for operation ofthe AgEagle that all relevant materials for operation be kept in a location accessible to the operator in a manner befitting current and future regulations.

14 C.F.R. 61.113(a) 

### &(b) 

### &14 C.F.R. 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. Section 61.113(a) & (b) limit private pilots to noncommercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the AgEagle in this
case is remotely controlled with no passengers or property ofothers on board. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraft for compensation or hire. AgEagle respectfully proposes that operator requirements should take into account the characteristics ofthe particular sUAS. The AgEagle has a high degree of pre-programmed control and various built-in technical capabilities through the DroneDeploy solution that strictly limit the potential for operation outside ofthe operating conditions set forth in the exemption application.

The AgEagle operates by way of an all-digital software platform powered by DroneDeploy with advanced features previously available only to larger and more complex unmanned aircraft. Automated features and advanced failsafe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility. As such, nearly all operations in the context ofwhat is traditionally handled



### Kentucky Windage 

### UAV LLC 270-889-3173and/or monitored by a pilot, either private or commercial, are handled by the autopilot under the auspice ofthe DroneDeploy system. Such features include:

• Intelligent fault handling- The system automatically detects potential issues with configurable automated response behavior such as a "return home" and landing routines.

• Automatic preflight checks- The system self-calibrates all of its sensors and performs diagnostics prior to takeoffto check for errors and no-fly situations.
• No-fly zones: The system has the ability to set up no-fly zones visually and using existing flight charts.

• Self-monitoring- Battery levels, GPS fix, radio connection(s), inflight wind speeds, and numerous other system and environmental conditions are continuously monitored, logged, and automatically handled by the system. In the event of a fault, the aircraft will perform the appropriate predefined fatal or non-fatal condition response.
• Battery communication: Flight time and battery minutes are available at all times to the operator. The aircraft will return to the mission point oforigin and land automatically ifthe operational limits are reached.

As a matter of principle as well as a matter ofgood business, flight safety is of utmost priority. TheAgEagle achieves this via the DroneDeploy system; presented to the operator in a means that limits the operators' ability to operate outside of acceptable safety parameters; regardless ofoperating environment or project. The AgEagle offers superior safety over manned aircraft by removing the operatorfrom presence on-board the aircraft and those potentially dangerous situations subsequently associated therein.

Given the aforementioned operational and safety features, Kentucky Windage UAV proposes that operators ofthe AgEagle should not be required to hold a commercial or private pilot certification. In lieu, operators will:

• Successfully complete and pass the FAA private pilot written examination or an FAA recognized equivalent.

• Complete a training program authorized by AgEagle, LLC for operation and maintenance ofthe AgEagle robotic aircraft system.
• Submit to a security background check equivalent to that currently required to obtain a private pilot's license.



### Kentucky Windage 

### UAV LLC 270-889-3173Kentucky Windage UAV notes that the FAA has found that equivalent safety factors have permitted operation ofsUAS by operators with similar qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at p. 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.44701

### (f) to waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety can and will be provided by those in operation ofthe AgEagle without a private pilot's certificate or a commercial pilot's certificate, underthe conditions set forth herein.

The risks associated with the operation ofthe AgEagle (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUAS as setforth above meets or exceeds the present level ofsafety provided under 14 C.F.R. 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under 61.133(a).



### 14 C.F.R. 91.7(a): Civil AircraftAirworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted to allow commercial operation of the AgEagle without an airworthiness certificate, no standard will existfor airworthiness ofthe AgEagle. Given the precedence for exemption issuances ofsUAS lacking a proper airworthiness certificateS, Kentucky Windage UAV respectfully requests that the AgEagle be considered in a similar context as an equivalent (if not higher level) of safety will be achieved by a combination ofthe fault monitoring ofthe DroneDeploy system, as well as compliance with all flight protocols contained within the AgEagle operational instructions before, during, and after each flight.



### 14 C.F.R. 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides that no person may operate a U.S.registered civil aircraft, "Forwhich an Airplane or Rotorcraft Flight Manual is not required by 21.5 ofthis chapter, unless there is available in the aircraft a current approved Airplane or

8 See Exemption Approvals 11480, 11567, 11066, 11136, 11166, 

### et. a/.



### KentuckyWindage UA V LLC 270-889-3173Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof."

Given the size and configuration ofthe AgEagle, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level ofsafety will be achieved by keeping the operational instructions at the ground control point where the operator in control ofthe AgEagle will have immediate access to it. Kentucky Windage UAV recognizes that the FAA has determined that relieffrom this sections is not necessary; allowing relevant materials to be kept accessible to the operator in compliance with the regulations. As in the context of 14 CFR 91.203(b), Kentucky Windage UAV prefers to have this matter documented in the order ofdue process so as to ensure a meaningful level ofcompliance. As mentioned prior, Kentucky Windage UAVwill require for operation ofthe AgEagle that all relevant materials for operation be kept in a location accessible to the operator in compliance with current and future regulations.



### 14 C.F.R. 91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As established in this request for exemption, Kentucky Windage UAVwill never operate the AgEagle higherthan 400 feet AGL. It will not be operated in congested or populated
areas. Flights conducted with the AgEagle will only take place on property with authorization ofthe the landowner and I or operator. Because sUAS aerial survey, mapping and inspection work can be, and is most often the case, accomplished at relatively low altitudes including altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.
Despite flying at lower altitudes than more conventional manned aircraft, an equivalent level of safety will be achieved given the size, weight, speed, and material with which the AgEagle is built. The AgEagle is not an aircraft built for transit; rather it is a survey tool that is transported via other means to its intended area ofoperation. Because ofthe inherent "fenced in" nature of its missions, that is, over land where affected individuals



### Kentucky WindageUA V LLC 270-889-3173will be aware ofthe flights, Kentucky Windage UAVfeels that a lower altitude operation actually provides a higher level of safety. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 7.5 lbs and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with a conventional aircraft operating at or below 500 feet AGL. Moreover, the low altitude operations ofthe AgEagle will maintain a separation between such sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.



### 14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The AgEagle batteries provide approximately 40 minutes of powered flight. Kentucky Windage UAVwould only conduct flight during the day; and without an exemption from 14 CFR 91.151, daytime flights would be limited to approximately 10 minutes in length. Given the limitations on its proposed operations and the location ofthose proposed operations, a longertime frame for flight in daylight VFR conditions is reasonable.
Operating the AgEagle without 30 minutes of reserve power does not beget the type of risks that Section 91.151 (a) was meantto prevent given the size and speed atwhich the UAS operates, as well as given the fact that Kentucky Windage UAV intends to maintain
a VLOS with the AgEagle at all times. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting AgEagle flights to 10 minutes would greatly reduce the utility ofthe aircraft. In the unlikely event that the AgEagle should run out of power, it would simply land on ground on which Kentucky Windage UAV had already been granted flight over by the landowner and 

### I or operator. Given its weight and construction material, the risks are less than contemplated by the current regulation.
Kentucky Windage UAV believes that an equivalent level ofsafety can be achieved by maintaining 10 minutes of reserve power, which, allowing 30 minutes offlight time, would be more than adequate to return the AgEagle to its planned landing zone from anywhere in its VLOS operating area. Similar exemptions have been granted to others in similar situations, including Exemptions 11480, 11567, 2689, 5745, 10650, and 11110.



### Kentucky WindageUAV LLC 270-889-317314 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(2) & 14 C.F.R. 91.417(a): Maintenance and Inspections Relating Thereto Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval ofthe aircraft for return to service.

Maintenance ofthe AgEagle is performed by the operator in accordance with the instruction materials provided with the AgEagle perthe guidance given during training from AgEagle LLC and 

### I or one of its authorized training affiliates. When instruction and training is followed by the aircraft operator, an equivalent level ofsafety can be achieved in lieu ofthe aforementioned maintenance and inspection criteria set forth in the C.F.R. because the inherent properties ofthe AgEagle itself including:

• The relatively small size and mechanical simplicity ofthe AgEagle

• Its lack of cargo, crew, or passengers
• Any AgEagle mission will not extend past a predetermined area for which the operator has permission to conduct flight operations.

• The operator is trained to inspect all maintenance points on the aircraft prior to flight.

As a trained operator is an individual with a greater level offamiliarity and understanding with the AgEagle platform, it follows that this person is also best suited to maintain the airworthiness ofthe aircraft in a context of a level of safety equivalent to that presently mandated.

All criteria pertinent to flight operations are logged by the DroneDeploy system and are available for immediate review by the operator. The DroneDeploy system also conducts
a diagnostic inspection of hardware and software systems prior to launch, with any inspection failure being sufficient to suspend flight operations until the problem is resolved.



### Kentucky Windage 

### UAV LLC 270-889-3173The AgEagle airframe is unique among its peers in that the manufacturer reinforces an otherwise standard foam airframe with sturdy and lightweight composite materials thus significantly reducing overall wear-and-tear to the airframe. Ifsuch an event occurs during operation that the airframe is rendered unsuitable for flight, the aircraft with take appropriate action to compensate to keep the aircraft airborne or terminate the mission in the context ofeither a Fatal or Non-Fatal Conditioned response (see Appendix C "Reliability", "Fault Tolerance" and "Emergency Procedures and System Failures").



### KentuckyWindage UA V LLC 270-889-3173Appendix B 

### Company Profile Kentucky Windage UAV Remote Sensing Systems, LLC {"Kentucky Windage UAV") is
a United States company located in Cadiz, Kentucky. Kentucky Windage UAVwas founded on a mission to provide second-to-none small Unmanned Aerial Systems {"sUAS") sales, support, and service enriched by scientific insight to its customers in and around Western Kentucky. The founding partners have over 15 years combined experience in Geographic Information Systems (GIS) and remote sensing; and our staff has a strong background in providing technology solutions to industries that insist on above-the-bar customer service, such as local government and public safety. Our knowledge ofthe acquisition methods, sensors, and deliverables associated with GIS, paired with a drive to provide insightful customer service puts Kentucky Windage UAV in a unique industry position to facilitate the adoption ofsUAS within agriculture and the rural business market as a whole. Kentucky Windage UAV continues to work with the agribusiness industry, cooperatives, local universities and the rural public at large to promote a positive "people first" view of unmanned systems.
Kentucky Windage UAV is the exclusive Western Kentucky dealerfor the AgEagle Robotic Aircraft System; engineered and manufactured by AgEagle, LLC; a United States Company located in Neodesha, Kansas. Kentucky Windage UAV is an authorized training center for AgEagle and licenses documentation and training materials to AgEagle for their customers internationally. According to the manufacturer, AgEagle systems have a demonstrated track record with respect to safety, logging over 19,080 operational hours while surveying approximately 1,272,000 acres to date without incident to property or person.



### Kentucky Windage UAV LLC 270-889-3173Appendix C


### Technical Specifications ofthe AgEagle Robotic Aircraft Systemg

The AgEagle can carry payloads up to 2.5 lbs and flies at a maximum wind threshold of 43 mph for sustained winds and wind gusts up to 55 mph. To this point, the AgEagle employs a system that automatically compensates for wind rather than relying on the operator to determine the impact ofthe wind with respect to the mission dynamic at the altitude the system is flying. The end result is a system capable of gathering high quality aerial survey data at higherwind thresholds; a trait that is imperative for many aerial inspection operations.

The AgEagle has an operational range of up to 20 Statute miles (17.38 Nautical Miles); however, software failsafes actively restrict the functional range to safe and appropriate distances in-line with Visual Line-Of-Sight ("VLOS") operation.

All flight operations are GPS controlled, making the system stable, steady, and easy to navigate. At any point that the operator is not explicitly in command ofthe system, the AgEagle automatically holds its position via GPS navigation (i.e. GPS hold for reliable location loiter). Image acquisition is also GPS controlled allowing for a sophisticated level ofcamera control that is also straightforward to operate. The flight control system employs GPS positioning and navigation as well as a variety of sensors including range-finding, barometric pressure, temperature, and wind speed to ensure a higher level of reliability with respect to other sUAS in its class.

Powered by the DroneDeploy autopilot enhancement solution, the AgEagle can be operated in both semi- and fully autonomous flight modes. In semi-autonomous mode, the operator controls flight operations in real-time via a map interface. For fully autonomous flights, pre-planned flight paths are programmed via the same map interface before the mission. All waypoints, landing zone points and flight area dimensions are all entered before the mission and stored completely in non-volatile aircraft memory, ensuring the AgEagle operates only within specified pre-programmed parameters.

The AgEagle includes many advanced safety features that make it a practical choice in the context of rural operation. Built-in intelligent fault handling allows the AgEagle to

9 Technical Specifications ofthe AgEagle have been provided to Kentucky Windage UAV by the manufacturer upon their request.



### KentuckyWindage UAV LLC 270-889-3173detect a system fault while in the air, and to automatically fly back to its takeoff location and land. Faults that can be detected include:

• Loss of radio communication

• Exceeded preset wind thresholds

• Low battery levels
• Operator-defined "no fly zones" as well as maximum flight ranges and altitudes In addition, the AgEagle must pass a series of automated flight checks initiated by the DroneDeploy system prior to launch to ensure the system is flight-ready.

The AgEagle can be operated entirely by a touchscreen or point-and-click map-based interface. Beyond safety, the responsibility ofthe operator is to program the aircraft with the proper navigation parameters, and allow the the autopilot system to control the operational minutiae. Data used for mission planning can be saved and flight plans can be re-used where appropriate.

The body ofdocumentation provided for instruction and operation ofthe AgEagle can be made available upon request10.



### 1. Physical Characteristics ofthe AgEagle

• Dimensions:

o 56 inch wingspan

o 26 inch length

o 6.5 inch height

• Weight (without payload, including batteries): 7 pounds
• Weight with sensor payload (takeoffweight): 7.5 pounds

• Fuel: Not Applicable

• Propulsion System

o Engine: One electric brushless DC motor.

o Power: Self-contained, high-duration Lithium Polymer ("LiPo") batteries monitored by the on-board autopilot via real-time data feeds to ensure maximum flight duration and subsystem safety processes.

o Charging: Battery charger included with the system monitors and balances current loads. Can be performed via standard wall outlet (AC), or using DC power.
• Landing: "Belly landing" utilizing a polycarbonate protective "skid" plate.

10 See Application Section 9: "Appendices, Attachments, and Confidentiality of Proprietary Documents"



### Kentucky Windage 

### UA V LLC 270-889-3173

### 2. Performance Characteristics ofthe AgEagle

• Maximum Altitude: 400 ft AGL

• Maximum Endurance: 40 minutes
• Maximum Range: Visual Line Of Sight ("VLOS")

• Weather Minimums: NotApplicable

• Winds Maximum: 40 mph (sustained)

• Minimum ceiling: VLOS

• Minimum visibility: VLOS

• Icing conditions: None (No-fly)

• Precipitation: None (No-fly)



### 3. Maintenance The AgEagle performs automatic preflight checks utilizing the DroneDeploy system. The failure of any preflight check will preventtakeoff. As an added measure ofsafety per instruction materials and training provided by AgEagle or one of its adjuncts, a qualified operator is to perform a visual inspection ofthe AgEagle priorto each flight. The preflight checklist includes (but is certainly not limited to):

• Visual inspection ofthe airframe, servos, and control surfaces

• Visual inspection of motor mount and propeller integrity

• Check charge of all batteries (aerial vehicle, command station, radio repeater station) Besides the tasks associated directly with the aforementioned preflight checks, the AgEagle is nearly maintenance free.


### 4. Reliability The system is designed for maximum reliability to maintain consistent performance over the product lifespan. Components experiencing routine wear include motors, batteries, and servos. Battery and motor conditions are monitored bythe DroneDeploy system with deviations reported instantaneously to the operator.

Contact with other objects sometimes during take-off, but usually during landing may
cause servos, pushrods, or controlling surfaces to become damaged. Damaged components are likely to be detected during the full visual inspection ofthe airframe performed before each flight. Likewise, structural damage affecting flight characteristics will be detected not only visually, but by onboard sensors via the DroneDeploy system
as well.



### KentuckyWindageUA V LLC 270-889-3173The AgEagle detects numerous conditions which may make flying unsafe, including (but not limited to) reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Automatic preflight checks prevent the AgEagle from taking off ifsuch conditions are present; or, ifthe condition is detected during flight, the system will trigger a Fatal Conditioned Response ("FCR") with respect to aforementioned fault detection system.


### 5. Fault Tolerance The key feature ofthe AgEagle fault tolerance is its mechanical simplicity. The AgEagle airframe is of a flying wing configuration with one electric motor and two elevon controlling surfaces. Failure ofthe motor or any component failure detectable by the system will be reported to the operator and will cause the AgEagle to perform an FCR
or Non-Fatal Conditioned Response ("NFCR"), depending on the type offailure.


### 6. Emergency Procedures and System Failures The AgEagle has extensive failure detection and handling capabilities. All failures are deeded to be either FCR or NFCR.

• Sensor Failure: Failure ofonboard flight instruments/sensors will degrade performance and will result in either a FCR or a NFCR, depending on their severity. Ifthe AgEagle becomes unstable due to sensorfailure, the autopilot system will trigger an appropriate landing response to prevent a fly-away condition.

• Motor Failure: Given the inherentfixed-wing airframe design, the AgEagle can be safely landed in the event of motorfailure. Such an event would be handled as an FCR or NFCR depending on severity and the autopilot system will trigger an appropriate landing response.
• Power Failure: A complete battery failure causing power loss to the sUAS will result in significantly degraded flight performance. However, given the minimal power consumption necessary to maintain radio link, autopilot, and control surface operation, a motor failure is more likely to occur before a complete power failure.

• Airframe Failure: Ifairframe is damaged in ways that impacts flight characteristics, the AgEagle will behave similar to as if an onboard flight instrument failed.

• Navigation System Failure: In a navigation system failure, degraded GPS will result in an FCR or NFCR depending on the severity ofthe failure(s).



### Kentucky WindageUA V LLC 270-889-3173• Low Battery Condition: Operator will be alerted ofa low battery condition and the aircraft will initiate landing procedures as soon as able.
• VLOS Loss: All flight operations will be conducted with the AgEagle within visual sight ofthe Pilot in Command ("PIC"). Ifthe PIC's view becomes obstructed and VLOS is lost, the PIC may instruct the AgEagle to loiter in its current position until VLOS is reestablished, orto return to the predetermined landing site, orto land at the current position.

• Security: The system and communication links are encrypted by proprietary software provided by the DroneDeploy system. 

### 7. Command and Control Systems The AgEagle Ground Control Station ("GCS") powered by DroneDeploy allows the operator simultaneous control over aircraft and sensor payload. Interface control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second. 

### Displayed on GCS:

• Position
• Navigation Route
• Aircraft Identifier

• Position

• Altitude
• Heading
• North Seeking Arrow

• Range to Target
• Calculated target position

• Date /time
• Sensor heading and orientation relative to aircraft


### Onboard Flight Instruments

• The AgEagle is equipped with an Inertial Navigation System including:

o 3-axis gyroscope

o 3-axis magnetometer

o GPS receiver

o Static pressure sensor

o Range-finding sensorfor precision AGL altitude measurement



### Kentucky WindageUA V LLC 

### 270-889-3173• The AgEagle is equipped onboard computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.).

• The AgEagle can operate autonomously; it does not require any input from groundbased equipment, or from the operator to remain airborne.

• Frequency Allocations: 

### 900 MHz, 

### 2.4 GHz, 5.8 GHz, 

### 1,700- 2,100 Mhz, custom
• A flight termination link to prevent a "fly away" or other potentially dangerous situations is available to the operator atthe GCS.
• The AgEagle is launched autonomously via catapult. A Landing Zone ("LZ") is designated by the operator prior to takeoff and identified in the GCS software. Landing is handled autonomously atthe cue ofthe operator after the completion ofthe survey mission. Between instruction sets from the operator, the AgEagle is programmed to autonomously loiter over the LZ until further operator instruction is provided.

• Maps specific to navigation and mission planning are provided via the Drone Deploy system, which are overlaid with GPS positional data from the AgEagle.

• Navigation waypoints can be created before and during flight operation. Overthe
course of normal operation, waypoints are combined to create a scan pattern-type flight pattern conducive to collecting nominal aerial survey data.
• The AgEagle combines the input from a multitude of sensors to create redundancies in the system. Even though the data from all sensors is required for optimal system performance, a single sensor malfunction is likely to result in degraded performance and possibly an FCR or NFCR, rather than leading to a catastrophic failure.



### KentuckyWindageUA V LLC 270-889-3173